This response is made on behalf of the Asset Management Group of SIFMA (“SIFMA AMG”) and the Asset Management Group of ASIFMA (“AAMG”).

SIFMA AMG brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceeds $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

AAMG is a separate and independent division of ASIFMA established to represent the interests and concerns of asset managers in Asia (excluding Japan and Australia). AAMG is made up of 35 of the largest global asset managers which have businesses and operations in Asia and focuses on issues that have regional and global impact or with cross-border implications.

We welcome the opportunity to respond the European Commission’s public consultation on the review of the AIFMD. As noted by the Commission in the report to the European Parliament and the Council assessing the application and scope of the AIFMD 2 – the framework has been fundamental to the development and continuous growth of the AIF sector in Europe since its introduction in 2011. The EU AIF market has been growing consistently when measured by net assets of AIFs and AuM with significant cross-border activity of AIFMs. Since 2011, total net assets of AIFs increased from 2.3 trillion EUR to 5.9 trillion EUR with cross-border distribution of AIFs doubling from 3% to 5.8% in the last two years. The AIFM passport has been a key enabler of this growth and wider cross-border distribution in AIFs – as confirmed by the General Survey of AIFMs, public authorities and institutional investors.